The European Commission (EC) has published in Annex III a new RoHS exemption entry 9(a)-III for hexavalent chromium as an anticorrosion agent in gas absorption heat pumps. This will take effect on September 1, 2023.

In the refrigerant solution for the carbon steel sealed circuit of gas absorption heat pumps, hexavalent chromium is used as an anticorrosion agent. Following a review of the exemption request, the Commission concludes that replacing this usage is currently scientifically and technically impracticable.

The exemption application evaluation, which included a technical and scientific assessment study, concluded that substitution of hexavalent chromium in the refrigerant solution is currently scientifically and technically impracticable, and that other heating technologies that do not use hexavalent chromium in the form of sodium chromate cannot offer equivalent functionality and performance. Gas absorption heat pumps can provide higher energy efficiency than condensing boiler technologies, aid in system replacement, and reduce carbon dioxide emissions.

A maximum concentration of 0.7 % hexavalent chromium by weight in the refrigerant solution is considered sufficient which is only valid for gas absorption heat pumps for space and water heating described in the requested exemption. This falls under category 1 "large household appliances" of Annex I to the RoHS Directive.

The below table shows details of the exempted applications.

Entry Exemption Scope and dates of applicability
9(a)-III Up to 0.7 % hexavalent chromium by weight, used as an anticorrosion agent in the working fluid of the carbon steel sealed circuit of gas absorption heat pumps for space and water heating Applies to category 1 and expires on 31 December 2026.

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